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Privacy policy

PCube Srl Unipersonale - Share Capital € 10,000 i.v. - C.C.I.A.A. of Venice - P.I. IT03757540277 - Registered office: Via Friuli Venezia Giulia, 8 - 30030 Pianiga (VE) (hereinafter the "Company" or "PCube"), as the data controller provides you below, pursuant to art. 13 and 14 of the European Regulation 679/2016 relating to the protection of personal data (hereinafter "GDPR"), information relating to the processing of personal data of subjects who have purchased, requested or used services and / or products provided by the Company ( hereinafter the "Customer").

Index
Type of data processed
Purpose of the processing
Legal basis of the processing
Processing methods
Communication, dissemination and transfer of data
Transfer of data abroad
What are the Customer's rights
Changes and updates

1. TYPE OF DATA PROCESSED

The personal data processed by the Company include, by way of example and not exhaustively, the following categories of data relating to the Customer:

(i) identification, contact and access data, such as name, surname, email address, telephone number and access credentials to the services and / or products provided by the Company;

(ii) navigation data, such as IP addresses, log data or domain names and other parameters relating to the computers, operating system and IT environment used;

(iii) product data, such as data relating to the products and / or services provided by the Company, which the Customer has requested, to which he has access or which he uses;

(iv) data on preferences, such as data relating to the Customer's preferences, activities and spending habits;

(v) payment and bank details, such as current account number or IBAN code;

(vi) data acquired from public sources, such as data of representatives and attorneys that are collected through, for example, the Chambers of Commerce or commercial information services;

(hereinafter jointly referred to as the "Data").

2. PURPOSE OF THE TREATMENT

Data processing is carried out by the Company in carrying out its economic and commercial activities for the following purposes:

a) allow the Customer to request, obtain, access and use the services and / or products provided by the Company;

b) fulfill the obligations deriving from the law, regulations or community legislation (eg tax and accounting obligations);

(the purposes referred to in letters a) and b) are jointly defined as the "Contractual Purposes")

c) to assert and defend their rights, including in the context of debt collection and credit assignment procedures, including through third parties;

d) for the analysis and improvement of the services and / or products offered;

e) to carry out a potential merger, sale of assets, sale of a business or business unit by disclosing and transferring the Data to the third party (s) involved;

(the purposes of letters c) and e) are jointly defined as the "Purposes of Legitimate Business Interest")

f) to provide the Customer, pursuant to Article 130 of Legislative Decree 196/2003 (the "Privacy Code"), marketing communications by e-mail on services and / or products similar to those that the Company provides, without prejudice to it being understood that, at any time, it will have the possibility to oppose the sending of such communications;

g) with the prior consent of the Client, to provide him with marketing communications relating to the products and services offered by the Company, to involve him in market research or other customer satisfaction initiatives through traditional communication channels such as paper mail and through automated communication tools such as emails, automatic messages and other remote communication tools;

h) with the prior consent of the Customer, to provide him with marketing communications in the manner referred to in letters f) and g) relating to the products and services of commercial partners belonging to the distribution network and commercial channels of the Company, to which Data may be disclosed and the list of which is available by contacting the Company using the methods indicated in this statement;

i) without prejudice to what is indicated in the following letter j), to perform, with the prior consent of the Customer, an analysis of the Customer's preferences, activities and spending habits, in order to send the marketing communications indicated above.

(the purposes from letters f) and i) are jointly defined as the "Marketing Purposes");

j) for the performance of minimally invasive forms of segmentation based, among other things, on categories of belonging such as the professional category to which it is possible to send communications for Marketing Purposes to the Customer in accordance with this information , the city / province / region in which it is based and the type of service and / or product provided by the Company.

(the purpose referred to in letter j) is defined "Purpose of Legitimate Marketing Interest").

3. LEGAL BASIS OF THE PROCESSING

Data processing is necessary with reference to the Contractual Purposes as such Data are necessary in order to:

provide the services and / or products requested in relation to the cases referred to in Section 2, letter a);
comply with the provisions of the applicable legislation as provided for in Section 2, letter b).
Should the Customer decide not to provide the Data necessary for the Contractual Purposes, the Company will be unable to provide you with the requested services.

The processing of data for the purposes of legitimate business interest is carried out pursuant to article 6, letter f) of the GDPR for the pursuit of the legitimate interest of the Company which is equally balanced with the interests, rights and freedoms of the Customer as the data processing activity is limited to what is strictly necessary for the execution of the operations indicated therein. The processing for the purposes of legitimate business interest is not mandatory and the customer may oppose this processing in the manner set out in this statement, but should he decide to oppose such processing, his data cannot be used for the purposes of Legitimate Business Interest, except in the event that the Company demonstrates the presence of overriding legitimate reasons or the exercise or defense of a right pursuant to Article 21 of the GDPR.

The processing of data for marketing purposes is based on:

as regards Section 2 letter f), on article 130 of the Privacy Code, which allows you to send marketing communications by e-mail regarding services and / or products similar to those provided, which the Customer may object to at the time of collection of the data and in any subsequent communication;
with regard to Section 2, letters g) to i), on the Client's consent.
The processing of data for Marketing Purposes is not mandatory. Therefore, in the event of opposition to marketing communications or refusal to provide the relative consent, or revocation of the same, the Customer will not receive the marketing communications referred to in Section 2 from letters f) to i). In any case, the Customer may revoke the consent to the processing of the Data and oppose the sending of all marketing communications at any time, through the methods provided for in this information.

Finally, the processing of the Data for Legitimate Marketing Interest Purposes is functional to the pursuit of a legitimate interest of the Company adequately balanced with the interests, rights and freedoms of the Customer in light of the limits imposed in Section 2 letter j). Even in this case, the processing for the purposes of legitimate marketing interest is not mandatory and the customer may oppose this processing in the manner referred to in this information, but if he were to oppose such processing he will no longer receive the relevant communications, without prejudice to the case in which the Company demonstrates the presence of overriding legitimate reasons or the exercise or defense of a right pursuant to Article 21 of the GDPR. In the event that the Customer wishes to obtain more information about the balancing of interests, rights and freedoms, he can contact the Company at any time in the manner indicated in this statement.

4. METHOD OF TREATMENT

The Data will be processed by the Company with electronic and manual systems according to the principles of correctness, loyalty and transparency provided for by the applicable legislation on the protection of personal data and protecting the Client's confidentiality through technical and organizational security measures to guarantee a level of security. adequate.

5. DATA STORAGE

The Data will be kept for the period of time necessary for the pursuit of the purposes for which such Data were collected, as stated in this statement. In any case, the following retention terms will apply with reference to the processing of Data for the following purposes:

a) for the Contractual Purposes and Legitimate Business Interest, the Data are kept for a period equal to the duration of the supply of the services and / or products requested by the Customer and for 10 years following the termination of the supply, subject to any renewals and cases in which storage for a subsequent period is required for any disputes, requests from the competent authorities or pursuant to applicable legislation;

b) for the Marketing Purposes referred to in Section 2, letters f) and g) and for the Purpose of Legitimate Marketing Interest, the Data are kept for a period equal to the duration of the provision of the services requested by the Customer and a period of 24 months following the last contact with the Customer to be understood, among others, the participation in a Company event, the use of a product or service provided by the Company or the opening of a newsletter (jointly defined as the "Last Contact" );

c) for Marketing Purposes referred to in Section 2, letter h), the Data are kept for a period of 12 months from registration;

d) for the Marketing Purposes referred to in Section 2, letter i), the Data are kept by the Company for a period equal to the duration of the provision of the services and / or products requested by the Customer and a period of 12 months following the Last Contact, while they are kept by third parties for a period of 12 months from registration.

 6. COMMUNICATION, DIFFUSION AND TRANSFER OF DATA

For the Contractual Purposes, the Data may be transferred to the following third parties who carry out activities functional to those referred to in the provision of the services and / or products requested by you located inside and outside the European Union: (a) third parties suppliers of assistance and consultancy services for the Company with reference to the activities of the technological, accounting, administrative, legal, insurance sectors (by way of example only); (b) in cases where the provision of the services and / or products requested by you requires the intervention of our commercial partners, the Company may share some Data with distributors, resellers, partners and suppliers that are part of the chain of distribution of the Company's products and services; (c) subjects and authorities whose right of access to the Data is expressly recognized by law, regulations or provisions issued by the competent authorities.

For the purposes of legitimate business interest, the data may be transferred to the following categories of recipients, located inside and outside the European Union: (a) third party suppliers of assistance and consultancy services for the Company with reference to the activities of the technological, accounting, administrative, legal, insurance sectors (by way of example only), (b) potential purchasers of the Company and entities resulting from the merger or any other form of transformation concerning the Company, (c) competent authorities.

For Marketing Purposes and for the Purposes of Legitimate Marketing Interest, the Data may be transferred to third parties in charge of processing the Data, providing assistance and consultancy services for the Company with reference to the activities of sending marketing communications located within and outside the European Union.

These recipients, depending on the case, process the Customer Data as owners, managers or processors. The complete and updated list of the subjects who process the Data as data processors is available upon request to the Data Protection Officer, according to the contact methods indicated in this statement.

 7. TRANSFER OF DATA ABROAD

The Data may be freely transferred outside the national territory to countries located in the European Union, but could also be transferred outside the European Union and in particular to the United States. With reference to transfers outside the European Union to countries not considered adequate by the European Commission, the Company adopts suitable and appropriate security measures to protect the Data. Consequently, any transfer of Data to countries located outside of the European Union will take place, in any case, in compliance with the appropriate and appropriate guarantees for the purposes of the transfer itself, such as the standard contractual clauses of data protection, pursuant to the applicable legislation and in particular of articles 45 and 46 of the GDPR.

In the event that the Customer wishes to obtain more information regarding the guarantees in place and request a copy of them, he can contact the Company at any time in the manner indicated in this statement.

8. WHAT ARE THE CUSTOMER'S RIGHTS
In relation to the processing of data described in this statement, the customer can exercise at any time the rights provided by the GDPR (articles 15-21), including:

receive confirmation of the existence of the data and access their content (right of access);
update, modify and / or correct the Data (right of rectification);
request the cancellation or limitation of the processing of data processed in violation of the law, including those whose retention is not necessary in relation to the purposes for which the data were collected or otherwise processed (right to be forgotten and right to limitation);
oppose the processing (right to object);
revoke the consent, where given, without prejudice to the lawfulness of the processing based on the consent given before the revocation;
propose a complaint to the Supervisory Authority (Guarantor for the protection of personal data www.garanteprivacy.it) in case of violation of the regulations on the protection of personal data;
receive an electronic copy of the Data concerning him, to transfer them to himself or to a different service provider, in the event that the Company carries out the processing of such Data on the basis of his consent or on the basis that the processing it is necessary for the provision of the requested services and / or products and the Data are processed through automated tools (right to data portability).
To exercise these rights, the Customer can contact the Data Protection Officer, who can be contacted by sending a request to privacy@pcube.it or by sending the communication by post to the Company's address indicated at the beginning of this information note indicating " To the c.a of the Data Protection Officer ".

In contacting us, the Customer must ensure that they include their name, email / postal address and / or telephone number (s) to ensure that their request can be handled correctly.

 9. CHANGES AND UPDATES
This information may be subject to changes also as a result of any changes and / or regulatory additions. The changes will be notified in advance and the constantly updated information text will be available on www.pcube.it and shop.pcube.it.